U.S. SECURITIES AND EXCHANGE COMMISSION

          Litigation Release No. 15710 / April 20, 1998

          UNITED STATES OF AMERICA V. BENJAMIN BUSH, Criminal Action No. 98
          CR 35 (C.D. Cal.)

          On April 7, 1998, Benjamin Bush ("Bush"), an investment adviser
          and president of his investment adviser managment firm, Ben Bush
          Investment Management, Inc. ("BBIM"), pleaded guilty to one count
          of money laundering.  Bush will be sentenced on June 29, 1998.
          The Securities and Exchange Commission obtained Judgments of
          Permanent Injunction and Other Relief against Bush and BBIM on
          January 24, 1997 based on the same conduct.  The judgments
          permanently enjoin Bush and BBIM from future violations of
          Section 17(a) of the Securities Act of 1933, Section 10(b) of the
          Securities Exchange Act of 1934 and Rule 10b-5 thereunder and
          Sections 206(1) and 206(2) of the Investment Advisers Act of 1940
          ("Advisers Act"), antifraud provisions; Section 206(4) of the
          Advisers Act and Rule 206(4)-2 thereunder, custody and possession
          violations; Section 204 of the Advisers Act and Rules 204-
          1(b)(2), 204-2(a) and 204-2(b) thereunder, books and records
          violations; and Section 207 of the Advisers Act, registration
          filings violations.  The judgments further provide that Bush and
          BBIM shall pay disgorgement, prejudgment interest, and civil
          penalties in amounts subsequently to be determined by the Court.
          Bush and BBIM consented to the entry of the judgments without
          admitting or denying the Commission's allegations.  In addition,
          Bush agreed to be barred from the securities industry, and BBIM
          consented to a revocation of its registration as an investment
          adviser.

          In its complaint, the Commission alleged that Bush, through BBIM,
          managed approximately $10 million for wealthy and sophisticated
          clients nationwide.  The Commission alleged, among other things,
          that from January 1995 through the filing of the Commission's
          action on September 25, 1996, Bush:
          (a) misappropriated at least $450,000 of his clients' funds
          accepting money from clients to purchase investments on their
          behalf, but failing to purchase the investments; (b) commingled
          client funds with his own funds in a single corporate bank
          account which he used like a private checking account to pay his
          own expenses, such as rent, alimony and car insurance, and to
          purchase such personal items as hockey tickets and jewelry; (c)
          sent his clients false account statements, fraudulently showing
          that he had purchased investments on their behalf; (d) used
          forged brokerage statements to solicit clients' business; and (e)
          induced several of his clients to purchase Brazilian bonds of
          uncertain value issued in 1902 and 1915 which Bush kept in his
          safety deposit box at his local bank.

          On September 26, 1996, the Commission obtained a temporary
          restraining order against Bush and BBIM which ordered them to
          immediately cease their fraudulent activities, and an order
          placing a freeze on Bush's assets to protect investor funds.  On
          October 4, 1996, the Court entered a preliminary injunction
          against Bush and BBIM, which continued to bar them from their
          fraudulent activities and continued the asset freeze.

          For further information, see Litigation Release Nos. 15101,
          15132, and 15241.